“USC and Kiffin engaged in improper means in their procurement of the breach and were not legally justified in their actions. Kiffin and USC’s actions, through him, were part of a course and pattern of conduct fostered by Kiffin and USC to use improper methods and means to the direct harm and damage of parties to contracts ...”

The Titans declined to comment Monday beyond the lawsuit.

Titans coach Jeff Fisher, a Southern California alumnus, said Saturday that Kiffin neglected to make the customary courtesy phone call to let him and the NFL team know he was interested in hiring Pola. Fisher himself had hired Pola, letting go Earnest Byner to free up the spot on his coaching staff.

Pola’s contract ran at least to Feb. 14, 2011, with the NFL in the final year of its current labor agreement with the players.

The lawsuit lawsuit notes that written permission from the president and general counsel was needed because verbal “consent is inadequate.” The lawsuit also notes Southern California and Kiffin, through Pola, knew about his contract requirements.

“Pola was not given express written consent by Tennessee Football or the Commissioner of the NFL to entertain employment with any other entity,” the lawsuit argues.

The move left the Titans without a running backs coach one week before training camp opens, which the lawsuit argues disrupts planning, causes “potential loss of confidence by players” and the loss of salary and benefits already paid to Pola along with “future damage.”

The lawsuit is particularly harsh on Kiffin for what it calls intentional actions. Kiffin said he first spoke to Pola on Friday, and then called Fisher on Saturday after Pola called him back, apparently to accept the job.

Kiffin acknowledged in a statement that timing wasn’t perfect.

“I have spoken with Coach Fisher and he now has an accurate understanding of the timeline of events,” Kiffin said. “We realize the timing of this isn’t perfect for all parties, but this is a great opportunity and promotion for Kennedy.”

Fisher told The Tennessean newspaper he was very disappointed in Kiffin’s lack of professionalism. The lawsuit doesn’t hold back in criticizing Kiffin for “furtherance of a culture of violation and avoidance of respect for the sanctity of contract, which Kiffin similarly practices ...” in inducing Pola to breach his contract.

The lawsuit notes Kiffin “abruptly departed” his coaching job at the University of Tennessee in January after just 14 months, which angered Volunteers’ fans. Kiffin also lured four other Tennessee coaches to join him at Southern California, and the lawsuit also notes how Kiffin tried to hire Eric Bienemy away from NFL’s Vikings, forcing Minnesota to redo his contract to keep the assistant.

The lawsuit asks for a jury trial and punitive damages and attorneys fees.